American Airlines Inc v. Transport Workers Union of America, AFL-CIO
4:19-cv-00414
N.D. Tex.Aug 12, 2019Background
- American Airlines sued TWU, IAM, and the joint Association alleging a concerted slowdown by mechanics during CBA negotiations that caused increased maintenance-related delays and cancellations and disrupted interstate commerce.
- Parties negotiated new CBAs after the merger of American and US Airways; negotiations intensified in 2019 with communications (Feb. 4 CBS report; Feb. 4 TWU letter; Mar. 8 IAM letter) that coincided with productivity declines.
- Plaintiff presented statistical regression evidence (expert Darin Lee) showing statistically significant increases in outstanding MELs, unscheduled AOS, delays, and cancellations after those communications, controlling for other factors (aircraft age, departures, pilot write-ups, weather, etc.).
- The court found the trends not attributable to other explanations and concluded mechanics engaged in concerted reduced productivity; defendants did not take reasonable steps to stop it after the March 8 letter.
- The court concluded defendants violated Section 2, First of the Railway Labor Act (RLA) and granted a permanent injunction in form proposed by plaintiff to enforce the unions’ duty to exert every reasonable effort to restore the status quo.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mechanics engaged in a concerted slowdown disrupting commerce | Statistical/regression evidence shows significant post-communications increases in MELs, AOS, delays, cancellations | Increases due to other factors (pilot write-ups, seasonal volume, CBS report, random variation) | Held for plaintiff: regression controlled for those factors; concerted slowdown found |
| Whether unions have duty to exert reasonable efforts to stop slowdown even if they didn't authorize it | RLA §152, First imposes affirmative duty on unions to prevent/discourage work actions; injunction proper to enforce that duty | Unions claimed lack of notice and argued they did not participate/authorize; compliance with TRO negates liability | Held for plaintiff: March 8 letter provided notice; unions failed to exert every reasonable effort; liability under RLA established |
| Whether injunctive relief is necessary and equitable | Injunction is the only practical, effective means to enforce unions’ duty; monetary damages inadequate; employer discipline insufficient | Permanent injunction too broad/vague; may harm public safety or suppress speech; should be limited or temporary | Held for plaintiff: injunction is necessary, equitable, and not contrary to public interest; tailored to require unions to exert reasonable efforts and direct members to cease calls for slowdown |
| Whether injunction provisions (productivity benchmark, speech restrictions) are impermissibly vague or prior restraints | Proposed terms enforce RLA duty to restore status quo and are specific enough | Claimed paragraph (o) sets an unlawful productivity target; paragraph (j) is a prior restraint on speech | Held for plaintiff: court rejected vagueness and prior-restraint arguments; provisions found sufficiently specific and lawful to enforce RLA duties |
Key Cases Cited
- Conrail v. Ry. Labor Exec. Ass'n, 491 U.S. 299 (1989) (distinguishes major v. minor disputes under the RLA and supports federal jurisdiction for major disputes)
- Chicago & N.W. Ry. Co. v. United Transp. Union, 402 U.S. 570 (1971) (injunction may be the only practical means to enforce status quo duty under RLA)
- eBay Inc. v. MercExchange, L.L.C., 547 U.S. 388 (2006) (four-factor equitable test for permanent injunctions)
- Int'l Ass'n of Machinists & Aerospace Workers v. United Air Lines, 243 F.3d 349 (7th Cir. 2001) (RLA status quo duty: unions must exert reasonable efforts to stop concerted work actions)
- Delta Air Lines, Inc. v. Air Line Pilots Ass'n, Int'l, 238 F.3d 1300 (11th Cir. 2001) (upholding injunction where concerted action disrupted operations)
- Burlington N. & Santa Fe Ry. Co. v. Brotherhood of Maint. of Way Emps., 286 F.3d 803 (5th Cir. 2002) (no monetary remedy for violations of Section 2, First of RLA)